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Wausau Paper Towel & Tissue, LLC

Wausau Paper Towel & Tissue, LLC

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 4:14-cv-01437: Wausau Paper Towel & Tissue, LLC. Filed in U.S. District Court for the Southern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-lavs for more info.
Official Complaint for Patent Infringement in Civil Action No. 4:14-cv-01437: Wausau Paper Towel & Tissue, LLC. Filed in U.S. District Court for the Southern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-lavs for more info.

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Published by: PriorSmart on May 23, 2014
Copyright:Public Domain

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05/23/2014

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IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION WAUSAU PAPER TOWEL & TISSUE, LLC A Wisconsin limited liability company,
Plaintiff,
v. Civil Action No. ________ Cordell Inc. d/b/a Ridley’s Vacuum and Janitorial Supply A Texas corporation
COMPLAINT JURY TRIAL DEMANDED
 Defendant.
Plaintiff, Wausau Paper Towel & Tissue, LLC, alleges as follows:
THE PARTIES
 1.
 
Plaintiff, Wausau Paper Towel & Tissue, LLC (“Wausau”), is a limited liability company organized and existing under the laws of Wisconsin and having a principal place of  business at 100 Paper Place, Mosinee, Wisconsin. 2.
 
On information and belief, Defendant, Cordell Inc., is a corporation organized and existing under the laws of Texas and having a principal place of business at 3700 Reveille Street, Houston, Texas 77087. On information and belief, Cordell Inc. does business as Ridley’s Vacuum and Janitorial Supply (“Ridley’s”).
 
JURISDICTION AND VENUE
3.
 
This is a case for patent infringement arising under the Acts of Congress relating to patents, 35 U.S.C. §§ 271; 282-285. This Court has jurisdiction under 28 U.S.C. §§ 1331 and 1338(a). 4.
 
Jurisdiction is proper because, on information and belief, Defendant transacts  business in this judicial district including the sales and offering for sale of its products, has committed acts of infringement in this judicial district and Defendant has sufficient contacts with this judicial district to subject itself to the jurisdiction of this Court. 5.
 
Venue is proper in this district under 28 U.S.C. § 1391(b) and (c) and 28 U.S.C. § 1400(b).
BACKGROUND
6.
 
Wausau is engaged in the business of manufacturing and selling various paper towel and tissue products, including paper roll products, to customers around the world. 7.
 
On December 10, 2002, United States Patent No. 6,491,251 (“the ’251 patent”), entitled “Double Core Tissue Roll, Dispenser and Method” was duly and legally issued to Wausau as an assignee of the inventors, Mark Harrison Stanland, Steven M. Slye, Douglas E. Bagan, Alain P. Cotnoir, Randy A. Baughman, and Adam T. Elliott. 8.
 
Wausau is the owner of the entire right, title and interest in and to the ’251 patent, and has been and continues to be the owner. A copy of the ’251 patent is attached as Exhibit A. 9.
 
On November 18, 2003, United States Patent No. 6,648,267 (“the ’267 patent”), entitled “Double Core Tissue Roll, Dispenser and Method” was duly and legally issued to Wausau as an assignee of the inventors, Mark Harrison Stanland, Steven M. Slye, Douglas E. Bagan, Alain P. Cotnoir, Randy A. Baughman, and Adam T. Elliott. 2
 
10.
 
Wausau is the owner of the entire right, title and interest in and to the ’267 patent, and has been and continues to be the owner. A copy of the ’267 patent is attached as Exhibit B. 11.
 
These patents are directed at paper roll products with spaced core sections, including a process for making paper roll products with spaced core sections. 12.
 
Ridley’s is engaged in the business of importing, using, selling and offering for sale paper roll products with spaced core sections. On information and belief, Ridley’s  purposefully imports paper roll products with spaced core sections from abroad and sells them throughout the United States. A photograph of a sample accused paper roll product with spaced core sections, branded “ELEGANCE BATH TISSUE”, is attached hereto as Exhibit C. 13.
 
On information and belief, the paper roll products with spaced core sections are made by unlawfully performing the claimed processes as disclosed in the ’251 and ’267 patents. 14.
 
On information and belief, Ridley’s purchases and imports the paper roll products with spaced core sections manufactured by practicing the claimed processes in the ’251 and ’267  patents outside the United States and without permission from Wausau. 15.
 
On information and belief, the foreign manufacturer’s activities would directly infringe, contribute to the infringement of, and/or induce infringement of the ’251 and ’267  patents through the performance of the claimed process in the United States.
COUNT I - INFRINGEMENT OF U.S. PATENT NO. 6,491,251
 16.
 
Wausau restates the allegations set forth in paragraphs 1-15 and incorporate them herein by reference. 17.
 
By virtue of its ownership of the ’251 patent, Wausau maintains the right to sue thereon and the right to recover for infringement thereof. 3

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